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AFM/ESA consumer warnings remain ongoing (AFM warnings since Nov 2017; joint EBA/EIOPA/ESMA warning post-MiCA application). CASPs must maintain Title V complaints-handling procedures. NL-specific application of AFM's turbo-certificate-style conduct-of-business supervision to crypto remains unconfirmed.
On the conduct-of-business side, MiCA-authorised CASPs operating in the Netherlands are required to establish complaints-handling procedures under MiCA Title V. A further, more speculative observation this cycle notes that the AFM applies supervisory expectations analogous to its established enforcement approach on leveraged "turbo" certificates when assessing CASP conduct-of-business obligations toward Dutch retail clients; however, no crypto-specific appropriateness rule paralleling the turbo-certificate regime was directly confirmed in this research cycle, and this observation should be treated as an inference rather than a confirmed supervisory practice.
Outlook
The consumer-protection module's framework-level elements — AFM warnings, ESA joint warnings, and Title V complaints-handling — are stable and unlikely to change materially in the near term. The open item is whether AFM's turbo-certificate-style conduct-of-business posture is ever formally extended, or confirmed as extended, to crypto-asset appropriateness assessments specifically; until that is confirmed against a primary AFM enforcement source, this remains an inference rather than an established supervisory fact.
Consumer Protection
The AFM conducted a review of thirty-three crypto-asset providers assessing compliance with MiCA's marketing and cost-disclosure standards. The review identified significant shortcomings in advertising practices at fourteen of the providers reviewed, and found inadequate cost information at nineteen. Findings concerning ten international providers were shared with other European regulators, indicating the AFM is treating this as a cross-border supervisory matter rather than one confined to domestically-incorporated firms.
This review represents an active 2026 enforcement priority for the AFM, sitting within its MiCA conduct-supervision remit, though it has not this cycle produced a fine or formal order against any named provider; the finding is supervisory in nature. The scale of the review, covering a third of providers surveyed with advertising shortcomings and well over half found to have inadequate cost information, signals that marketing and cost-transparency compliance across the crypto sector reaching Dutch consumers falls meaningfully short of the MiCA standard as currently enforced.
Outlook
Whether any of the AFM's findings from this review will progress to a formal fine or order against a named provider, and whether the ten providers referred to other European regulators face coordinated follow-on action, has not been independently verified this cycle and remains a live question for the next observation window.
2 earlier distinct update(s)
Consumer Protection
The AFM treats advertising and marketing compliance by unlicensed crypto-asset service providers targeting Dutch clients as an active enforcement priority for 2026. This reflects a consumer-protection posture focused on policing the boundary of the MiCA CASP perimeter, specifically ensuring that platforms without AFM authorisation are not able to market to Dutch residents as though they held equivalent standing to licensed CASPs.
The clearest illustration of this enforcement priority is Binance's continued unavailability to Dutch residents as of mid-2026, reflecting the fact that Binance holds no MiCA CASP licence in the Netherlands. This is a significant data point for consumer-protection purposes because it demonstrates the AFM's willingness to maintain exclusion of a major global platform from the Dutch retail market for as long as that platform remains outside the CASP licensing perimeter, rather than tolerating unlicensed access on the basis of the platform's scale or international standing elsewhere.
Outlook
The AFM's active 2026 enforcement priority against unlicensed marketing suggests continued scrutiny of any platform operating without CASP authorisation while targeting Dutch clients. Whether Binance or other major unlicensed platforms move toward AFM authorisation, or continue to operate outside the Dutch market entirely, is the practical marker to track for how this enforcement priority translates into market-access outcomes.
Consumer Protection
The AFM has taken to publicly naming unlicensed crypto venues operating in the Dutch market, including the exchange MEXC, as a consumer-facing enforcement and warning measure. This is a Probable-confidence finding resting on a single T3 secondary source, and it should be read as a a posture signal rather than a formal sanction: the AFM is not merely relying on the MiCA authorisation requirement itself to exclude unlicensed operators from the market, but is actively publicising the names of venues operating without the required authorisation so that Dutch consumers can identify them.
This naming practice sits alongside, but is analytically distinct from, the MiCA authorisation regime itself, which requires CASPs to hold AFM-issued authorisation to professionally provide crypto-asset services in the Netherlands. Where a venue lacks that authorisation and continues to serve Dutch consumers, the AFM's response this cycle has been public disclosure rather than, on the evidence available, a formal enforcement order. The practical consumer-protection effect is to shift some of the burden of avoiding unlicensed venues onto consumer awareness, supplementing rather than replacing the underlying licensing gate.
Outlook
Whether the AFM's naming practice expands to a larger list of unlicensed venues, or is followed by formal enforcement action against named entities, will indicate whether this is a standing consumer-protection tool or an initial, isolated measure. No further corroborating source was retrieved this cycle beyond the single T3 report.
Sources and findings (4)
- T1 · EBAAFM — public warnings on virtual currencies, crypto-assets and initial coin offerings, an ongoing consumer information initiative running since November 2017retrieved M3bindingin force
- T1 · EBA/EIOPA/ESMAEBA, EIOPA and ESMA (European Supervisory Authorities) — a joint consumer warning following MiCA's application, noting that crypto-asset investor protections may be limited depending on the type of crypto-asset involvedretrieved M4bindingin force
- T1 · ESMAAFM — its enforcement approach on leveraged 'turbo' certificates when assessing CASP conduct-of-business obligations for crypto-assets offered to Dutch retail clients, though no crypto-specific appropriateness rule was directly confirmed in this runretrieved M2non-binding
- T1 · ESMAMiCA-authorised CASPs operating in the Netherlands — complaints-handling procedures under MiCA Title V conduct-of-business obligationsretrieved M3bindingin force